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America's ambassador to Bucharest described the law as a "tragedy", which would bar thousands of childless couples legitimately providing some of Romania's 40,000 orphans with a high standard of living in the US.

But Emma Nicholson, the EU observer for Romania, has described the practice as kidnapping.

Sonia Botezatu, Romania's under-secretary for child protection and adoption, said that after the dictator Nicolae Ceaucescu was executed in 1989, the adoption system was unregulated and awash with corruption.

"There was lots of money changing hands, and foreign adoption associations received a certain number of children depending on how much money they paid," she said.

The sale of children abroad was suspended in 2000, but according to Miss Botezatu, many foreign adoption agencies simply bypassed local authorities, offering cash directly to impoverished parents.

"The United States more than anywhere has fed expectations of potential adoptive parents," she said.